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Documentation, Resources & Implementation Milestones Presented - - PowerPoint PPT Presentation

Session 1 Documentation, Resources & Implementation Milestones Presented by: Nick Halsey Data Standardisation and Analytics An agency of the European Union Agenda Why is EudraVigilance changing? How is EudraVigilance changing?


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An agency of the European Union

Session 1 – Documentation, Resources & Implementation Milestones

Presented by: Nick Halsey Data Standardisation and Analytics

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Agenda

  • Why is EudraVigilance changing?
  • How is EudraVigilance changing?
  • How to prepare for technical changes?
  • Technical Support, & available Documentation

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Project Milestones

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Why is EudraVigilance changing? (1/4)

  • Post authorisation legal requirement changes
  • In December 2010, the pharmacovigilance legislation was updated through

amendments to Regulation (EC) No 726/2004 and Directive 2001/83/EC, followed by the addition of Commission Implementing Regulation (EU) No 520/2012 in June 2012.

  • The main changes to electronic reporting requirements are:
  • Usage of ISO standards in the reporting of ICSRs, ISO ICSR standard 27953-

2:2011

  • Usage of ISO IDMP terminologies, once available, in the submission of ISO ICSR

messages

  • EMA Medical Literature monitoring service
  • The Audit of the EudraVigilance system
  • Centralisation of reporting of ICSRs in the EU and forwarding of national cases to

the relevant NCA.

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Why is EudraVigilance changing? (2/4)

  • Clinical Trials legal requirement changes
  • The new Clinical Trials Regulation (Regulation (EU) No 536/2014)

will apply as from six months after the publication of the Commission notice about the full functionality of the EU portal and database, and no earlier than 28th May 2016.

  • According to the Regulation, the Agency shall set up and maintain

an electronic database for the reporting of SUSARs and annual safety reports. The database shall be a module of the EudraVigilance database.

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Why is EudraVigilance changing? (3/4)

  • The main planned changes to electronic reporting

requirements are:

  • Usage of ISO standards in the reporting of SUSARs, ISO ICSR

standard 27953-2:2011

  • Usage of ISO IDMP set of standards and terminologies, once

available, in the submission of ISO ICSR messages

  • Centralisation of reporting SUSARs in the EU
  • Development of a standard web-based structured form for the

SUSARs reporting by sponsors to EudraVigilance; This form would be ISO ICSR 27953-2:2011 (E2B(R3)) compliant.

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Why is EudraVigilance changing? (3/4)

  • Revision of the EudraVigilance Access Policy
  • Article 24(2) of the Regulation defines the level of EudraVigilance access as

follows:

  • EudraVigilance shall be fully accessible to the competent authorities of the Member

States and to the Agency and the European Commission.

  • It shall also be accessible to MAHs to the extent necessary for them to comply with

their pharmacovigilance obligations.

  • The Agency shall ensure that healthcare professionals and the public have

appropriate levels of access to the EudraVigilance database, while guaranteeing personal data protection.

  • Article 28(c) of Regulation (EC) No 726/2004 further states that:
  • The Agency shall make available promptly all suspected adverse reaction reports
  • ccurring in the Union to the WHO.

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How is EudraVigilance changing? (1/4)

  • In December 2013, the EMA Management Board endorsed

the “EudraVigilance Auditable requirements” :

  • Simplified reporting of side effect reports for MAHs with re-

routing to NCAs

  • Provision of reports to WHO (respecting EU data protection

legislation)

  • EV access for MAHs to conduct product monitoring including

signal detection (respecting EU data protection legislation)

  • Publication of data and search availability for healthcare

professionals and the public for all medicines authorised in the EU

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How is EudraVigilance changing? (2/4)

  • Continued:
  • Compliance with international ICSR standards (and compatibility

with IDMP standards based on Article 57 data) by 1 July 2016 including backwards and forwards conversion tools for E2B(R2)/(R3) messages

  • Conversion of legacy data (> 7 mill. ICSRs currently held in EV)
  • System performance and scalability based on increased number of

users and volume of data

  • Security (authentication, authorisation and data transaction to limit

the risks of unauthorised access)

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How is EudraVigilance changing? (3/4)

  • EudraVigilance Audit:
  • Functional specifications were prepared by the Agency in

collaboration with Member States and the Commission to address required changes

  • Functional specifications were endorsed by EMA Management Board

in December 2013 and are subject to an independent audit (“auditable requirements”)

  • EMA Management Board is to announce when Eudravigilance

database has achieved full functionality and the system meets the functional specifications based on

  • Independent audit report
  • Recommendation of the Pharmacovigilance Risk Assessment Committee
  • Simplification of adverse reaction reporting will apply six months

following the announcement by the Board

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How is EudraVigilance changing? (4/4)

  • Key milestones:
  • New EV system stakeholder testing: start End of Q2 2016
  • Scope: to provide opportunity to selected MAHs to test the new

functionalities implemented in the EV system.

  • New EVTEST system available to stakeholder for testing: Q4

2016

  • Training launch: Q1 2017
  • Go-live: July 2017

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How to prepare for technical changes?

  • Implementing ISO ICSR (E2B(R3)) support in MAH’s

PhV systems:

  • MAHs need to consider implementing a fully ISO ICSR

compliant system or to use a backwards/forwards conversion tool in order to support the processing of the E2B(R3) format ICSRs and acknowledgements from EV.

  • Understand and apply new E2B(R3) principles (e.g.

seriousness at event level, amendment reports, additional drug role characterisation)

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How to prepare for technical changes?

  • Electronic Gateway for ICSR transmission:
  • Current software solution will remain the same, however

configuration changes may be needed to support E2B(R3) messages including acknowledgments from EV.

  • As only submissions of ICSRs to the EV will be considered as

fulfilling the MAH’s legal obligations, MAHs should ensure that modifications to their submission systems are configured and tested well in advance of the planned implementation.

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How to prepare for technical changes?

  • MAH Testing:
  • No testing with NCAs
  • MAHs are required to test once they are ready to implement the new

system supporting the submission of E2B(R3) ICSRs, using the new simplify testing process with EMA.

  • MAHs should plan to complete any testing of their existing systems 6 to 3

months prior to the new EV system going live in order to give time for any issues to be addressed

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How to prepare for technical changes?

  • EV-WEB:
  • a new version of this application will be released to support

E2B(R3) format ICSRs data entry. MAHs should plan to start training of their staff 6 months in advance of the new system being implemented followed by regular refresher training at least 3 months and 2 weeks before implementation.

  • EV Downloading ICSRs concerning MAH’s products:
  • a download tool will be made available in order for MAH to

download ICSRs concerning their products.

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How to prepare for technical changes?

  • The new EV system and ISO IDMP, xEVMPD/Article 57
  • The future use of the ISO IDMP standard in the context of the new ICH

E2B(R3) format is further elaborated in the EU Individual Case Safety Report (ICSR) Implementation Guide (EMA/51938/2013 )

  • Art.57/xEVMPD database, which contains core data elements from the ISO

IDMP standard, serves as the dictionary for medicinal product information until the ISO IDMP standards implementation

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How to prepare for technical changes?

  • For the ISO IDMP standards and terminologies, an incremental

introduction is planned over time taking into account the migration of the existing xEVMPD/Article 57 content as the starting point

  • Please refer to dedicated webpage “Implementation of the ISO

IDMP standards” on the EMA website for ongoing activities and next steps (http://www.ema.europa.eu/ema/index.jsp?curl=pages/regulat ion/general/general_content_000645.jsp&mid=WC0b01ac0580 78fbe2)

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How to prepare for Business process changes?

  • Centralised reporting of ICSRs to EudraVigilance:
  • MAH will need to ensure that all reportable ICSRs are submitted

to EudraVigilance only, including EEA non-serious within 90 days.

  • Planning should be put in place to ensure MAHs are ready to

report directly to EudraVigilance prior to move to centralised reporting .

  • MAHs using EV-WEB will need to plan for an increase in resources

for the manual data entry of non-serious EEA cases into EudraVigilance, taking into account that the number of non- serious cases received is generally higher than serious cases.

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How to prepare for Business process changes?

  • MAH Signal validation and management process:
  • MAHs will have the legal obligation to monitor data

available in EV and to inform the Agency and NCAs about any validated signals they identify.

  • The new process for signals validated by MAHs will be

designed, discussed and consulted during the 1st revision

  • f the GVP Module IX on signal management (Public

consultation planned for 2nd quarter of 2016).

  • Other guidance documents, including training materials,

will be created and provided as relevant. MAHs should put in place training for their staff concerning this new process.

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How to prepare for Business process changes?

– MAH Signal validation and management process

  • MAHs will be granted access to the EudraVigilance Data Analysis system in
  • rder to comply with their pharmacovigilance obligations and use the signal

detection and analytical reporting functions (e.g. electronic reaction monitoring report and ICSR line listings).

  • MAHs should put in place training for their staff concerning this new tool and

register their staff to have access to it.

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How to prepare for Business process changes?

  • Reporting of SUSARs to EudraVigilance:
  • Until the Clinical Trials regulation is applicable, there is no change

to the current process for the submission of SUSARs for clinical trials approved through the Clinical Trials directive 2001/20/EC.

  • Clinical Trials approved through the Clinical Trials directive

2001/20/EC will continue to have the same SUSAR reporting requirements as specified in the directive for a transition period

  • f 3 years after the Clinical Trials regulation is applicable.
  • Note: Option will remain for small organisations to report SUSARs directly

to the NCA that has approved the trial through establishing an agreement between the sponsor and the NCA concerned. The NCA will then forward these SUSARs to EV.

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What training will be available? (1/2)

  • Training should be planned for MAH staff on the new business process and new IT

systems at least 6 months prior to implementation in order to be ready once the new EudraVigilance system is implemented.

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  • Module based online training approach

for all users accessible through the EMA website

  • The online learning comprises the use of:
  • Information videos,
  • Contextual help in EV Web
  • User Manuals,
  • Demo videos,
  • Competency assessments.
  • Limited face to face trainings based on a

train the trainer approach might be

  • ffered.

Flexible training paths

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What training will be available? (2/2)

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MAH Learning Path (under finalisation)

Pharmacovigilance Operations New EudraVigilance Functionalities New EudraVigilance Functionalities - IT

E-learning Guidance Webinars Introduction to training offering by the EMA New EV functionalities and 2010 pharmacovigilance legislation Implementing ISO ICSR/ICH E2B R3 How to prepare for simplified adverse reaction reporting in the EU Revised EV Access policy – how does it impact

  • n MAHs and NCAs

Revised GVP guidelines – updates and impact Revised Signal Detection Guideline Revised GVP Module VI Revised GVP Module IX Pharmacovigilance Operations Support webinar How to register with EudraVigilance and EVDAS EV/EVDAS Functionalities webinar ISO ICSR standard implementation for IT system developers Gateway adaptations for ISO ISCR/ACK message exchange with Eudravigilance Instructions on how to test ICSR submissions to EV EVDAS Report Manual Webport user guide for ADR website EVDAS training for MAHs EudraVigilance export manager and ICSR download Overview of reporting process for EV users Introduction to EV system components and system functionalities All MAH users will have access to all training course. The learning path aims to indicate course best suited for each stakeholder group Medical Literature Monitoring by EMA – what’s new Medical Literature Monitoring service MAH’s level 1 access via EVDAS

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Built-in help in EV web (1/2)

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Built-in help in EV web (2/2)

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What communication will be available?

MAHs should consider developing a communication plan to ensure that the necessary information is circulated within their own organisation and with other organisations that they work with.

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Where to find further guidance and detailed information?

  • Dedicated EudraVigilance webpage at the Agency’s corporate website

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Change management plan

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http://www.ema.europa.eu/ema/pages/includes/document/open_document.jsp?webContentId=WC500196029

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http://www.ema.europa.eu/ema/index.jsp?curl=pages/regulation/q_and_a/q_and_a_detail_000149.jsp&mid=WC0b01ac05800250b5

Further guidance and detailed information

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  • The ISO standard provides the schema files (technical

structure) to be used to create ICSR messages

  • The ICH E2B(R3) implementation guide (IG) provides the core

set of requirements for the contents of messages

  • The EU Implementation Guide supplements the ICH E2B(R3)

IG with additional EU specific requirements

Relationship between ISO ICSR standard, ICH E2B(R3) & the EU Implementation Guides

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ICH & EU Documentation for ISO ICSR

  • Published Technical documentation
  • ICH Documentation (http://estri.ich.org)
  • ICH Implementation guide package
  • ICH E2B(R3) Questions & Answers (Q&As)
  • EU Documentation (http://www.ema.europa.eu)
  • EU Individual Case Safety Report (ICSR) Implementation Guide
  • These documents should not be read in isolation
  • The EU implementation has additional requirements
  • Additional Data elements to the ICH IG
  • Controlled vocabularies specific to the EU
  • Business rules (some optional fields in ICH are mandatory in the EU)

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EU Extensions to E2B(R3)

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EU Causality Assessment Reporting in ICSRs

  • EU Causality Assessment can be used for SUSAR (mandatory)

and post-authorisation reporting (optional)

  • Source of Assessment – e.g. Investigator, Sponsor, MAH, Health

Care professional

  • Result of Assessment - Reasonable possibility or No reasonable

possibility

  • Based on the CIOMS Working Group VI binary decision

causality assessment

  • The same assessment is used in E2B(R2) using free text fields.

In E2B(R3) these fields are controlled vocabularies

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Biological Products Requiring Batch Number

  • For suspected adverse reactions relating to biological medicinal

products, the identification of the concerned product with regard to its manufacturing is important

  • All appropriate measures should be taken to clearly identify the name
  • f the product and the batch number
  • The batch number field is mandatory in the EU for all suspect drugs
  • The nullflavor “ASKU” should be completed for biological products where the

primary source has been contacted for this information but is unable to provide it

  • The nullflavor “UNK” should be used for all other situations when this

information is missing

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Device Component and Device Batch number

  • Advanced therapies or involve medicinal products that have device

component(s) additional fields are available in the ISO ICSR to capture specific information about the device component(s)

  • Device ID – Will form part of ISO IDMP controlled vocabularies
  • Device name
  • Device batch/lot number
  • This information can be important where the reporter has suspected

that the device component may have led to the adverse reaction experienced by the patient or in cases of device failure.

  • The batch/lot number is separate and specific to the device and is

different to the medicinal product “box” level batch/lot number

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Usage of nullflavor flags

  • Nulflavors give a reason why a specific field in an ICSR is empty/blank
  • The HL7/ISO ICSR schema requires that some data elements must

always be part of the ICSR message even if ICH/EU IGs classifies those fields as optional. In such situations a nulflavor will be permitted

  • The EU implementation has some difference to the ICH IG. The ICH

IG allows some fields to be null however these fields are mandatory in the EU e.g Reporter Qualification, Literature Reference(s) & Study Registration Country

  • Nulflavors represent some technical challenges for implementing in IT

systems and for displaying in data entry tools

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EU ICSR Implementation Guide Business rules Spreadsheet

  • This Excel Spreadsheet contains all the business rules

contained in the EU implementation guide along with additional technical information

  • It can be used to easily identify ICH and EU data fields
  • Differences between the ICH business rules and EU business

rules are also highlighted

  • http://www.ema.europa.eu/docs/en_GB/document_library/Other/201

5/10/WC500196023.xlsx

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ICH/EU Reference Instances

40 http://www.ema.europa.eu/ema/pages/includes/document/open_document.jsp?webContentId=WC500196027

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ICH/EU Code lists

  • The EU Implementation includes 4 additional code lists to the

existing 27 ICH ones

  • 1 Code list for additional Message types e.g. backlog
  • 3 Code lists for SUSAR drug reaction assessments
  • Note – These can also be used for post-authorisation ICSRs

(Optional)

http://www.ema.europa.eu/ema/pages/includes/document/open_document.jsp? webContentId=WC500196025

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EU Example Instances

  • Example instances can be used for testing E2B(R3) and for

testing transmissions to the EudraVigilance system.

  • The file 05_Standard EV QA test cases-R3.xml is intended for

final testing with the EMA before moving a new system into production with EudraVigilance

  • http://www.ema.europa.eu/ema/pages/includes/document/op

en_document.jsp?webContentId=WC500196026

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ISO ICSR Standard

http://www.iso.org/iso/iso_catalogue/catalogue_tc/catalogue_detail.htm?csnumber=53825

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ISO ICSR Standard

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ISO ICSR Schema Location

http://eudravigilance.ema.europa.eu/xsd/ E2B(R3) XSD Reference:

http://eudravigilance.ema.europa.eu/xsd/multicacheschemas/MCCI_IN200100UV01.xsd

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ICH Technical info document

  • Contains useful information examples for structuring Time

intervals, Lab test results and dosage information

  • Warning – Some of the XPATHs in the document are

incorrect/incomplete. The ICH Reference message instance is the source of truth for ICH not this document.

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UCUM

  • For physical quantities and units of time HL7 Messaging uses

UCUM http://unitsofmeasure.org/ucum.html http://unitsofmeasure.org/graphics/ucum-state-automaton.gif

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Access policy

  • The access policy details which E2B(R3) data fields MAHs will

have access to in EudraVigilance and what conditions are placed on that access.

  • http://www.ema.europa.eu/ema/pages/includes/document/op

en_document.jsp?webContentId=WC500199048

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GVP module VI & IX and Clinical Trials updates

  • These Good Pharmacovigilance Practice business level

documents are being updated. During this update changes to the business rules might occur, therefore the EU Implementation Guide and supporting documents may also be revised to reflect the change in requirements

  • In addition the guidance for the Clinical Trials regulation is also

under discussion which can also lead to new requirements that would need to be reflected in the EU Implementation Guide and supporting documents.

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ISO IDMP implementation

  • Not planned for release as part of the new EudraVigilance

system in mid 2017.

  • ISO IDMP once established will be implemented in

EudraVigilance and its use is likely to become mandatory for use by all organisations at some point after that. E2B(R2) would no longer be support for submission as part of this implementation

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